Main Street Capital Corporation, et al.; Notice of Application, 28175-28178 [E8-10802]
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Federal Register / Vol. 73, No. 95 / Thursday, May 15, 2008 / Notices
classified; and (3) if applicable, the
beneficiary developing country.
Petitions and requests must be
submitted, in English, to the Chairman
of the GSP Subcommittee, Trade Policy
Staff Committee. Submissions in
response to this notice will be available
for public inspection by appointment
with the staff of the USTR Public
Reading Room, except for information
granted ‘‘business confidential’’ status
pursuant to 15 CFR 2003.6. If the
submission contains business
confidential information, a nonconfidential version of the submission
must also be submitted that indicates
where confidential information was
redacted by inserting asterisks where
material was deleted. In addition, the
confidential submission must be clearly
marked ‘‘BUSINESS CONFIDENTIAL’’
in large, bold letters at the top and
bottom of each and every page of the
document. The public version that does
not contain business confidential
information must also be clearly marked
in large, bold letters at the top and
bottom of each and every page (either
‘‘PUBLIC VERSION’’ or ‘‘NONCONFIDENTIAL’’). Documents that are
submitted without any marking might
not be accepted or will be considered
public documents.
In order to facilitate prompt
consideration of submissions, USTR
requires electronic mail (e-mail)
submissions in response to this notice.
Hand-delivered submissions will not be
accepted. E-mail submissions should be
single copy transmissions in English
with the total submission including
attachments not to exceed 30 pages in
12-point type and 3 megabytes as a
digital file attached to an e-mail
transmission. Submissions should use
the following e-mail subject line: ‘‘2008
Annual GSP Review-Petition.’’
Documents must be submitted as either
WordPerfect (‘‘.WPD’’), MSWord
(‘‘.DOC’’), text (‘‘.TXT’’), or Adobe
(‘‘PDF’’) files. Documents cannot be
submitted as electronic image files or
contain embedded images (for example,
‘‘.JPG’’, ‘‘.TIF’’, ‘‘.BMP’’, or ‘‘.GIF’’).
Supporting documentation submitted as
spreadsheets are acceptable as Quattro
Pro or Excel, pre-formatted for printing
on 81⁄2 x 11 inch paper. To the extent
possible, any data attachments to the
submission should be included in the
same file as the submission itself, and
not as separate files. E-mail submissions
should not include separate cover letters
or messages in the message area of the
e-mail; information that might appear in
any cover letter should be included
directly in the attached file containing
the submission itself, including
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identifying information on the sender,
organization name, address, telephone
number, and e-mail address. The
electronic mail address for these
submissions is FR0807@ustr.eop.gov
(Note: The digit before the number in
the e-mail address is the number ‘‘zero,’’
not a letter.) Documents not submitted
in accordance with these instructions
may not be considered in this review. If
unable to provide submissions by email, please contact the GSP
Subcommittee to arrange for an
alternative method of transmission.
For any document containing
business confidential information
submitted as an electronic attached file
to an e-mail transmission, in addition to
the proper marking at the top and
bottom of each page as previously
specified, the file name of the business
confidential version should begin with
the characters ‘‘BC-’’, and the file name
of the public version should begin with
the characters ‘‘P-’’. The ‘‘P-’’ or ‘‘BC-’’
should be followed by the name of the
person or party (government, company,
union, association, etc.) submitting the
petition.
Public versions of all documents
relating to this review will be available
for public review approximately 30 days
after the due date by appointment in the
USTR Public Reading Room, 1724 F
Street, NW., Washington, DC.
Availability of documents may be
ascertained, and appointments may be
made from 9:30 a.m. to noon and 1 to
4 p.m., Monday through Friday, by
calling 202–395–6186.
Marideth Sandler,
Executive Director, GSP Program Chairman,
GSP Subcommittee of the Trade Policy Staff
Committee.
[FR Doc. E8–10917 Filed 5–14–08; 8:45 am]
BILLING CODE 3190–W8–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–28265; 812–13438]
Main Street Capital Corporation, et al.;
Notice of Application
May 8, 2008.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under section 57(i) of the
Investment Company Act of 1940 (the
‘‘Act’’) and rule 17d–1 under the Act to
permit certain joint transactions
otherwise prohibited by section 57(a)(4)
of the Act and under section 17(d) of the
Act and rule 17d–1 under the Act
authorizing certain joint transactions.
AGENCY:
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Applicants
request an order to permit a business
development company (‘‘BDC’’) and its
wholly-owned small business
investment company (‘‘SBIC’’) to coinvest with certain affiliates in portfolio
companies.
APPLICANTS: Main Street Capital
Corporation (the ‘‘Company’’), Main
Street Mezzanine Fund, LP (‘‘MSMF’’),
Main Street Capital II, LP (‘‘MSC’’) and
Main Street Capital Partners, LLC (the
‘‘Investment Adviser’’).
FILING DATES: The application was filed
on October 12, 2007, and amended on
April 28, 2008.
HEARING OR NOTIFICATION OF HEARING: An
order granting the requested relief will
be issued unless the Commission orders
a hearing. Interested persons may
request a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on June 2, 2008, and
should be accompanied by proof of
service on applicants, in the form of an
affidavit or, for lawyers, a certificate of
service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F St.,
NE., Washington, DC 20549–1520.
Applicants: c/o Mr. Vincent D. Foster,
Main Street Capital Corporation, 1300
Post Oak Boulevard, Suite 800, Houston,
TX 77056.
FOR FURTHER INFORMATION CONTACT: Jean
E. Minarick, Senior Counsel, at (202)
551–6811, or Nadya B. Roytblat,
Assistant Director, at (202) 551–6821
(Office of Investment Company
Regulation, Division of Investment
Management).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained for a fee at the
Commission’s Public Reference Branch,
100 F St., NE., Washington, DC 20549–
1520 (tel. 202–551–5850).
SUMMARY OF APPLICATION:
Applicants’ Representations
1. The Company is an internally
managed, non-diversified, closed-end
management investment company that
has elected to be regulated as a BDC
under the Act.1 The Company’s
1 Section 2(a)(48) defines a BDC to be any closedend investment company that operates for the
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investment objective is to maximize
total return by generating current
income from debt investments and
realizing capital appreciation from
equity-related investments. The
Company’s investments are managed by
an investment committee (‘‘Investment
Committee’’). The Company has a sixmember board of directors (‘‘Board’’) of
which four members are not interested
persons of the Company within the
meaning of section 2(a)(19) of the Act
(‘‘Independent Directors’’).
2. MSMF is organized as a limited
partnership that operates as an SBIC,
and is excluded from the definition of
investment company by section 3(c)(7)
of the Act. MSMF is a wholly-owned
subsidiary of the Company. MSMF has
the same investment objective and
strategies as the Company. Main Street
Mezzanine Management, LLC is the
general partner of MSMF and a whollyowned subsidiary of the Company. The
Investment Adviser, a wholly-owned
subsidiary of the Company, acts as
MSMF’s manager and investment
adviser.
3. MSC is a limited partnership that
operates as an SBIC, and is excluded
from the definition of investment
company by section 3(c)(7) of the Act.
MSC has the same investment objective
and strategies as the Company and
MSMF. The general partner of MSC is
Main Street Capital II GP, LLC
(‘‘MSIIGP’’). Certain individuals who
comprise the management of the
Company are also members of MSIIGP.
Since its inception MSC has, and it will
continue to have, the same investment
objective and strategies as MSMF and
the Company. As a result, prior to the
Company’s election to be regulated as a
BDC, MSC and MSMF, as a general
practice, invested jointly in portfolio
companies (the ‘‘Existing CoInvestments’’). As of December 31, 2007,
MSC had debt and equity investments
in 17 portfolio companies with an
aggregate fair market value of $67
million. In addition, MSC had $40
million of outstanding indebtedness
guaranteed by the Small Business
Administration, which had a weighted
average annualized interest cost of 6.4%
(exclusive of deferred financing costs) as
of September 30, 2007. MSMF is also
invested in 13 of the 17 portfolio
companies in which MSC is invested.2
purpose of making investments in securities
described in sections 55(a)(1) through 55(a)(3) of the
Act and makes available significant managerial
assistance with respect to the issuers of such
securities.
2 The one time that MSMF and MSC did not coinvest is during a period when MSMF was fully
invested, excluding a reasonable cash cushion.
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The Investment Adviser manages the
investment activities of MSC.
4. The Investment Adviser is a wholly
owned subsidiary of the Company and
is exempt from registration under the
Investment Advisers Act of 1940. The
management of the Investment Adviser
is comprised of the same individuals
who comprise the Investment
Committee of the Company. The
Investment Adviser may in the future
advise other entities that are affiliated
persons of the Company as defined in
sections 2(a)(3)(C) and (D) of the Act
(the ‘‘Future Co-Investment Affiliates,’’
and together with MSMF, MSC and the
Company, the ‘‘Co-Investment
Affiliates’’).3 Applicants request relief
permitting the Co-Investment Affiliates
to co-invest in portfolio companies (the
‘‘Co-Investment Program’’ and each
investment, a ‘‘Co-Investment
Transaction’’). Under the Co-Investment
Program, co-investment between the
Company, MSMF and MSC would be
the norm, rather than the exception. In
selecting investments for the Company,
the Investment Committee will consider
only the investment objective,
investment policies, investment
position, capital available for
investment, and other pertinent factors
applicable to the Company. Under the
Co-Investment Program, each coinvestment would be allocated among
the Company and MSMF, on the one
hand, and MSC, on the other hand,
based upon the relative total capital of
each group (total capital being equal to
raised equity plus available debt). These
relative allocation percentages
(‘‘Relative Allocation Percentages’’)
would be approved each quarter or, as
necessary or appropriate, between
quarters by both the full Board and the
required majority (within the meaning
of Section 57(o)) (the ‘‘Required
Majority’’).4 Because MSMF and MSC
are subject to SBIC regulation while the
Company is not, some deviation from
the Relative Allocation Percentages may
be necessary (the ‘‘SBIC Exceptions’’).
For example, if the Investment
Committee has selected an investment
for the Company and that investment
does not qualify under SBIC regulations,
3 Sections 2(a)(3)(C) and 2(a)(3)(D) define an
‘‘affiliated person’’ of another person as: (C) Any
person directly or indirectly controlling, controlled
by, or under common control with, such other
person; (D) any officer, director, partner, copartner,
or employee of such other person.
4 The term ‘‘Required Majority,’’ when used with
respect to the approval of a proposed transaction,
plan, or arrangement, means both a majority of a
BDC’s directors or general partners who have no
financial interest in such transaction, plan, or
arrangement and a majority of such directors or
general partners who are not interested persons of
such company.
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only the Company would pursue the
investment. The Co-Investment Program
as a whole has been approved by both
the full Board and the Required
Majority. The Relative Allocation
Percentages will be approved by both
the full Board and the Required Majority
prior to the implementation of the CoInvestment Program, and any deviations
from the Relative Allocation Percentages
for any investment, by any of the
Company, MSMF, or MSC, except for
the SBIC Exception, would require prior
approval by both the full Board and the
Required Majority.
Applicants’ Legal Analysis
1. Section 57(a)(4) of the Act prohibits
certain affiliated persons of a BDC from
participating in a joint transaction with
the BDC in contravention of rules as
prescribed by the Commission. In
addition, under section 57(b)(2) of the
Act, any person who is directly or
indirectly controlling, controlled by or
under common control with a BDC is
subject to section 57(a)(4). Because
certain individuals who are the
members of MSIIGP also comprise the
Investment Committee and are the
principals of the Investment Adviser,
and collectively own approximately
18% of the outstanding voting securities
of the Company, the Company, MSMF
and MSC are affiliated persons within
the meaning of section 2(a)(3) by reason
of common control. Thus, MSC could be
deemed to be a person related to the
Company in a manner described by
section 57(b) and therefore, is
prohibited by section 57(a)(4) and rule
17d–1 under the Act from participating
in the Co-Investment Program. Section
57(i) of the Act provides that, until the
Commission prescribes rules under
section 57(a)(4), the Commission’s rules
under section 17(d) of the Act
applicable to registered closed-end
investment companies will be deemed
to apply. Because the Commission has
not adopted any rules under section
57(a)(4), rule 17d–1 applies.
2. Section 17(d) of the Act and rule
17d–1 under the Act prohibit affiliated
persons of a registered investment
company from participating in joint
transactions with the company unless
the Commission has granted an order
permitting such transactions. Rule 17d–
1, as made applicable to BDCs by
section 57(i), prohibits any person who
is related to a BDC in a manner
described in section 57(b), as modified
by rule 57b–1, acting as principal, from
participating in, or affecting any
transaction in connection with, any
joint enterprise or other joint
arrangement or profit-sharing plan in
which the BDC is a participant, absent
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an order from the Commission. In
passing upon applications under rule
17d–1, the Commission considers
whether the company’s participation in
the joint transaction is consistent with
the provisions, policies, and purposes of
the Act and the extent to which such
participation is on a basis different from
or less advantageous than that of other
participants.
3. Applicants state that allowing coinvestment in portfolio companies by
the Company, MSMF and MSC will
increase favorable investment
opportunities for the Company and
MSMF. The Co-Investment Program has
been approved by the Board and the
Required Majority on the basis that it
would be mutually advantageous for the
Company and MSMF to have the
additional capital from MSC available to
meet the funding requirements of
attractive investments in portfolio
companies.
4. Applicants state that the formulae
for the allocation of co-investment
opportunities among the Company and
MSMF on the one hand and MSC on the
other, and the protective conditions set
forth below will ensure that the
Company will be treated fairly.
Applicants state that the proposed relief
is consistent with rule 17d–1 in that the
participation of the Company and
MSMF will not be on a basis different
from or less advantageous than that of
MSC.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Each time the Investment Adviser
considers an investment for MSC, the
Investment Committee, for the
Company, and the Investment Adviser,
for MSMF, will make an independent
determination of the appropriateness of
the investment for the Company and
MSMF.
2. (a) If the Investment Committee, for
the Company, and the Investment
Adviser, for MSMF, deem that each
entity’s participation in the investment
is appropriate, then such investment
will be made pursuant to the Relative
Allocation Percentages, unless either the
Investment Committee or the
Investment Adviser determines that
investment pursuant to the Relative
Allocation Percentages is not
appropriate for that investment. The
Relative Allocation Percentages will be
determined by both the full Board and
the Required Majority in advance and
will be based upon the relative total
capital of the Company and MSMF, on
the one hand, and MSC, on the other
hand (total capital being equal to raised
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equity plus available debt). The Relative
Allocation Percentages will be approved
each quarter, or as necessary or
appropriate, between quarters, by both
the full Board and the Required
Majority, and may be adjusted, for
subsequent transactions, in their sole
discretion for any reason, including,
among other things, changes in the
relative aggregate capital of the
`
Company and MSMF vis-a-vis the
capital of MSC.
(b) If the Investment Committee, for
the Company, and the Investment
Adviser, for MSMF, deem that each
entity’s participation in the CoInvestment Transaction is appropriate,
but that investment pursuant to the
Relative Allocation Percentages is not
appropriate, then the Investment
Committee, for the Company, and the
Investment Adviser, for MSMF, will
recommend an appropriate level of
investment for each entity. If the
aggregate amount recommended by the
Investment Committee, for the
Company, and the Investment Adviser,
for MSMF, to be invested in such CoInvestment Transaction, together with
the amount proposed to be invested by
MSC in the same transaction, exceeds
the amount of the investment
opportunity, the amount proposed to be
invested by each such party will be
allocated among them pro rata based on
the ratio of the Company’s and MSMF’s
total assets, on one hand, and MSC’s
total assets, on the other hand, to the
aggregated total assets of the three
parties, up to the amount proposed to be
invested by each. The Investment
Adviser will provide the Required
Majority with information concerning
MSC’s total assets to assist the Required
Majority with their review of the
Company’s and MSMF’s investments for
compliance with these allocation
procedures. After making the
determinations required in this
paragraph (b), the Investment
Committee and the Investment Adviser
will distribute written information
concerning the Co-Investment
Transaction, including the amount
proposed to be invested by MSC, to the
Independent Directors for their
consideration. Outside of the Relative
Allocation Percentages, the Company
and MSMF will co-invest with MSC
only if, prior to the Company’s and
MSC’s participation in the CoInvestment Transaction, a Required
Majority concludes that:
(i) The terms of the transaction,
including the consideration to be paid,
are reasonable and fair and do not
involve overreaching of the Company or
its stockholders or MSMF on the part of
any person concerned;
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(ii) The transaction is consistent with
(A) The interests of the stockholders
of the Company; and
(B) The Company’s investment
objectives and strategies (as described in
the Company’s registration statements
on Form N–2 and other filings made
with the Commission by the Company
under the Securities Act of 1933, as
amended (‘‘Securities Act’’), reports
filed by the Company with the
Commission under the Securities
Exchange Act of 1934, as amended, and
the Company’s reports to stockholders);
(iii) The investment by MSC would
not disadvantage the Company or
MSMF, and participation by the
Company and MSMF is not on a basis
different from or less advantageous than
that of MSC; provided, that if MSC, but
not the Company or MSMF, gains the
right to nominate a director for election
to a portfolio company’s board of
directors or the right to have a board
observer or any similar right to
participate in the governance or
management of the portfolio company,
such event shall not be interpreted to
prohibit the Required Majority from
reaching the conclusions required by
this condition (2)(b)(iii), if
(A) The Required Majority shall have
the right to ratify the selection of such
director or board observer, if any, and
(B) The Investment Adviser agrees to,
and does, provide, periodic reports to
the Company’s Board with respect to the
actions of such director or the
information received by such board
observer or obtained through the
exercise of any similar right to
participate in the governance or
management of the portfolio company;
and;
(iv) The proposed investment by the
Company and MSMF will not benefit
the Investment Adviser or MSC or any
affiliated person of either of them (other
than the Company, MSMF, and MSC),
except to the extent permitted under
sections 17(e) and 57(k) of the Act.
3. The Company and MSMF have the
right to decline to participate in any CoInvestment Transaction or to invest less
than the amount proposed.
4. Except for follow-on investments
made pursuant to condition 7 below, the
Company and MSC will not invest in
any portfolio company in which MSC or
any affiliated person of MSC is an
investor.
5. The Company and MSMF will not
participate in any Co-Investment
Transaction unless the terms,
conditions, price, class of securities to
be purchased, settlement date, and
registration rights will be the same for
the Company and MSMF as for MSC.
The grant to MSC, but not the Company
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or MSMF, of the right to nominate a
director for election to a portfolio
company’s board of directors, the right
to have an observer on the board of
directors or similar rights to participate
in the governance or management of the
portfolio company will not be
interpreted so as to violate this
condition 5, if conditions 2(c)(iii)(A)
and (B) are met.
6. Any sale, exchange, or other
disposition by the Company, MSMF, or
MSC of an interest in a security that was
acquired in a Co-Investment Transaction
or that is an Existing Co-Investment will
be accomplished pro rata based on the
original investment of each participant
unless the Investment Adviser and/or
the Investment Committee formulate a
recommendation for participation in a
disposition on a non-pro rata basis and
such recommendation is approved by
the Required Majority on the basis that
such non-pro rata disposition is in the
best interest of the Company and
MSMF. The Company, MSMF, and MSC
will each bear its own expenses in
connection with any disposition, and
the terms and conditions of any
disposition will apply equally to all
participants.
7. Any ‘‘follow-on investment’’ (i.e.,
an additional investment in the same
entity) by the Company, MSMF, or
MSC, or any exercising of warrants or
other rights to purchase securities of the
issuer in a portfolio company whose
securities were acquired as an Existing
Co-Investment or in a Co-Investment
Transaction will be accomplished pro
rata based on the original investment of
each participant unless the Investment
Adviser and/or the Investment
Committee formulate a recommendation
for participation in the proposed
transaction on a non-pro rata basis and
such recommendation is approved by
the Required Majority on the basis that
such non-pro rata participation is in the
best interest of the Company and
MSMF. The acquisition of follow-on
investments as permitted by this
condition will be subject to the other
conditions set forth in the application.
8. The Independent Directors will be
provided quarterly for review all
information concerning (1) all
investments made by MSC during the
preceding quarter and (2) Co-Investment
Transactions during the preceding
quarter, including investments made by
MSC which the Company and/or MSMF
considered but declined to participate
in, so that the Independent Directors
may determine whether the conditions
of the order have been met. In addition,
the Independent Directors will consider
at least annually the continued
appropriateness of the standards
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16:18 May 14, 2008
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established for co-investments by the
Company and MSMF, including
whether the use of the standards
continues to be in the best interests of
the Company and its shareholders and
does not involve overreaching on the
part of any person concerned.
9. The Company and MSMF will
maintain the records required by section
57(f)(3) of the Act as if each of the
investments permitted under these
conditions were approved by the
Independent Directors under section
57(f).
10. No Independent Directors will
also be a director, general partner or
principal, or otherwise an ‘‘affiliated
person’’ (as defined in the Act) of, MSC.
11. The expenses, if any, associated
with acquiring, holding or disposing of
any securities acquired in a CoInvestment Transaction (including,
without limitation, the expenses of the
distribution of any such securities
registered for sale under the Securities
Act) shall, to the extent not payable by
the Investment Adviser under its
investment advisory agreements with
MSMF and MSC, be shared by the
Company, MSMF, and MSC in
proportion to the relative amounts of
their securities to be acquired or
disposed of, as the case may be.
12. Any transaction fee (including
break-up or commitment fees but
excluding broker’s fees contemplated by
section 17(e)(2) of the Act) received in
connection with a Co-Investment
Transaction will be distributed to the
Company, MSMF, and MSC on a pro
rata basis based on the amount they
invested or committed, as the case may
be, in such Co-Investment Transaction.
MSC or any affiliated person of the
Company will not receive additional
compensation or remuneration of any
kind (other than (i) the pro rata
transaction fees described above and (ii)
investment advisory fees paid in
accordance with investment advisory
agreements with MSMF and MSC) as a
result of or in connection with a CoInvestment Transaction.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8–10802 Filed 5–14–08; 8:45 am]
BILLING CODE 8010–01–P
PO 00000
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–57805; File No. SR–
NYSEArca–2008–46]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing of Proposed
Rule Change Relating to the Listing
and Trading of Shares of the NETS
ISEQ 20 Index Fund (Ireland)
May 8, 2008.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on May 8,
2008, NYSE Arca, Inc. (‘‘NYSE Arca’’ or
‘‘Exchange’’), through its wholly owned
subsidiary, NYSE Arca Equities, Inc.
(‘‘NYSE Arca Equities’’), filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
substantially prepared by the Exchange.
The Commission is publishing this
notice to solicit comments on the
proposed rule change from interested
persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to list and
trade the shares (‘‘Shares’’) of the NETS
ISEQ 20 Index Fund (Ireland) (‘‘Fund’’)
issued by the NETS Trust (‘‘Trust’’). The
text of the proposed rule change is
available at the Exchange, the
Commission’s Public Reference Room,
and https://www.nyse.com.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of, and basis for,
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in Sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to list and
trade the Shares pursuant to NYSE Arca
1 15
2 17
Frm 00081
Fmt 4703
Sfmt 4703
U.S.C. 78s(b)(1).
CFR 240.19b–4.
E:\FR\FM\15MYN1.SGM
15MYN1
Agencies
[Federal Register Volume 73, Number 95 (Thursday, May 15, 2008)]
[Notices]
[Pages 28175-28178]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-10802]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-28265; 812-13438]
Main Street Capital Corporation, et al.; Notice of Application
May 8, 2008.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under section 57(i) of the
Investment Company Act of 1940 (the ``Act'') and rule 17d-1 under the
Act to permit certain joint transactions otherwise prohibited by
section 57(a)(4) of the Act and under section 17(d) of the Act and rule
17d-1 under the Act authorizing certain joint transactions.
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Summary of Application: Applicants request an order to permit a
business development company (``BDC'') and its wholly-owned small
business investment company (``SBIC'') to co-invest with certain
affiliates in portfolio companies.
Applicants: Main Street Capital Corporation (the ``Company''), Main
Street Mezzanine Fund, LP (``MSMF''), Main Street Capital II, LP
(``MSC'') and Main Street Capital Partners, LLC (the ``Investment
Adviser'').
Filing Dates: The application was filed on October 12, 2007, and
amended on April 28, 2008.
Hearing or Notification of Hearing: An order granting the requested
relief will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on June 2, 2008, and should be accompanied by proof of
service on applicants, in the form of an affidavit or, for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
St., NE., Washington, DC 20549-1520. Applicants: c/o Mr. Vincent D.
Foster, Main Street Capital Corporation, 1300 Post Oak Boulevard, Suite
800, Houston, TX 77056.
FOR FURTHER INFORMATION CONTACT: Jean E. Minarick, Senior Counsel, at
(202) 551-6811, or Nadya B. Roytblat, Assistant Director, at (202) 551-
6821 (Office of Investment Company Regulation, Division of Investment
Management).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained for a fee at the
Commission's Public Reference Branch, 100 F St., NE., Washington, DC
20549-1520 (tel. 202-551-5850).
Applicants' Representations
1. The Company is an internally managed, non-diversified, closed-
end management investment company that has elected to be regulated as a
BDC under the Act.\1\ The Company's
[[Page 28176]]
investment objective is to maximize total return by generating current
income from debt investments and realizing capital appreciation from
equity-related investments. The Company's investments are managed by an
investment committee (``Investment Committee''). The Company has a six-
member board of directors (``Board'') of which four members are not
interested persons of the Company within the meaning of section
2(a)(19) of the Act (``Independent Directors'').
2. MSMF is organized as a limited partnership that operates as an
SBIC, and is excluded from the definition of investment company by
section 3(c)(7) of the Act. MSMF is a wholly-owned subsidiary of the
Company. MSMF has the same investment objective and strategies as the
Company. Main Street Mezzanine Management, LLC is the general partner
of MSMF and a wholly-owned subsidiary of the Company. The Investment
Adviser, a wholly-owned subsidiary of the Company, acts as MSMF's
manager and investment adviser.
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\1\ Section 2(a)(48) defines a BDC to be any closed-end
investment company that operates for the purpose of making
investments in securities described in sections 55(a)(1) through
55(a)(3) of the Act and makes available significant managerial
assistance with respect to the issuers of such securities.
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3. MSC is a limited partnership that operates as an SBIC, and is
excluded from the definition of investment company by section 3(c)(7)
of the Act. MSC has the same investment objective and strategies as the
Company and MSMF. The general partner of MSC is Main Street Capital II
GP, LLC (``MSIIGP''). Certain individuals who comprise the management
of the Company are also members of MSIIGP. Since its inception MSC has,
and it will continue to have, the same investment objective and
strategies as MSMF and the Company. As a result, prior to the Company's
election to be regulated as a BDC, MSC and MSMF, as a general practice,
invested jointly in portfolio companies (the ``Existing Co-
Investments''). As of December 31, 2007, MSC had debt and equity
investments in 17 portfolio companies with an aggregate fair market
value of $67 million. In addition, MSC had $40 million of outstanding
indebtedness guaranteed by the Small Business Administration, which had
a weighted average annualized interest cost of 6.4% (exclusive of
deferred financing costs) as of September 30, 2007. MSMF is also
invested in 13 of the 17 portfolio companies in which MSC is
invested.\2\ The Investment Adviser manages the investment activities
of MSC.
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\2\ The one time that MSMF and MSC did not co-invest is during a
period when MSMF was fully invested, excluding a reasonable cash
cushion.
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4. The Investment Adviser is a wholly owned subsidiary of the
Company and is exempt from registration under the Investment Advisers
Act of 1940. The management of the Investment Adviser is comprised of
the same individuals who comprise the Investment Committee of the
Company. The Investment Adviser may in the future advise other entities
that are affiliated persons of the Company as defined in sections
2(a)(3)(C) and (D) of the Act (the ``Future Co-Investment Affiliates,''
and together with MSMF, MSC and the Company, the ``Co-Investment
Affiliates'').\3\ Applicants request relief permitting the Co-
Investment Affiliates to co-invest in portfolio companies (the ``Co-
Investment Program'' and each investment, a ``Co-Investment
Transaction''). Under the Co-Investment Program, co-investment between
the Company, MSMF and MSC would be the norm, rather than the exception.
In selecting investments for the Company, the Investment Committee will
consider only the investment objective, investment policies, investment
position, capital available for investment, and other pertinent factors
applicable to the Company. Under the Co-Investment Program, each co-
investment would be allocated among the Company and MSMF, on the one
hand, and MSC, on the other hand, based upon the relative total capital
of each group (total capital being equal to raised equity plus
available debt). These relative allocation percentages (``Relative
Allocation Percentages'') would be approved each quarter or, as
necessary or appropriate, between quarters by both the full Board and
the required majority (within the meaning of Section 57(o)) (the
``Required Majority'').\4\ Because MSMF and MSC are subject to SBIC
regulation while the Company is not, some deviation from the Relative
Allocation Percentages may be necessary (the ``SBIC Exceptions''). For
example, if the Investment Committee has selected an investment for the
Company and that investment does not qualify under SBIC regulations,
only the Company would pursue the investment. The Co-Investment Program
as a whole has been approved by both the full Board and the Required
Majority. The Relative Allocation Percentages will be approved by both
the full Board and the Required Majority prior to the implementation of
the Co-Investment Program, and any deviations from the Relative
Allocation Percentages for any investment, by any of the Company, MSMF,
or MSC, except for the SBIC Exception, would require prior approval by
both the full Board and the Required Majority.
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\3\ Sections 2(a)(3)(C) and 2(a)(3)(D) define an ``affiliated
person'' of another person as: (C) Any person directly or indirectly
controlling, controlled by, or under common control with, such other
person; (D) any officer, director, partner, copartner, or employee
of such other person.
\4\ The term ``Required Majority,'' when used with respect to
the approval of a proposed transaction, plan, or arrangement, means
both a majority of a BDC's directors or general partners who have no
financial interest in such transaction, plan, or arrangement and a
majority of such directors or general partners who are not
interested persons of such company.
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Applicants' Legal Analysis
1. Section 57(a)(4) of the Act prohibits certain affiliated persons
of a BDC from participating in a joint transaction with the BDC in
contravention of rules as prescribed by the Commission. In addition,
under section 57(b)(2) of the Act, any person who is directly or
indirectly controlling, controlled by or under common control with a
BDC is subject to section 57(a)(4). Because certain individuals who are
the members of MSIIGP also comprise the Investment Committee and are
the principals of the Investment Adviser, and collectively own
approximately 18% of the outstanding voting securities of the Company,
the Company, MSMF and MSC are affiliated persons within the meaning of
section 2(a)(3) by reason of common control. Thus, MSC could be deemed
to be a person related to the Company in a manner described by section
57(b) and therefore, is prohibited by section 57(a)(4) and rule 17d-1
under the Act from participating in the Co-Investment Program. Section
57(i) of the Act provides that, until the Commission prescribes rules
under section 57(a)(4), the Commission's rules under section 17(d) of
the Act applicable to registered closed-end investment companies will
be deemed to apply. Because the Commission has not adopted any rules
under section 57(a)(4), rule 17d-1 applies.
2. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
affiliated persons of a registered investment company from
participating in joint transactions with the company unless the
Commission has granted an order permitting such transactions. Rule 17d-
1, as made applicable to BDCs by section 57(i), prohibits any person
who is related to a BDC in a manner described in section 57(b), as
modified by rule 57b-1, acting as principal, from participating in, or
affecting any transaction in connection with, any joint enterprise or
other joint arrangement or profit-sharing plan in which the BDC is a
participant, absent
[[Page 28177]]
an order from the Commission. In passing upon applications under rule
17d-1, the Commission considers whether the company's participation in
the joint transaction is consistent with the provisions, policies, and
purposes of the Act and the extent to which such participation is on a
basis different from or less advantageous than that of other
participants.
3. Applicants state that allowing co-investment in portfolio
companies by the Company, MSMF and MSC will increase favorable
investment opportunities for the Company and MSMF. The Co-Investment
Program has been approved by the Board and the Required Majority on the
basis that it would be mutually advantageous for the Company and MSMF
to have the additional capital from MSC available to meet the funding
requirements of attractive investments in portfolio companies.
4. Applicants state that the formulae for the allocation of co-
investment opportunities among the Company and MSMF on the one hand and
MSC on the other, and the protective conditions set forth below will
ensure that the Company will be treated fairly. Applicants state that
the proposed relief is consistent with rule 17d-1 in that the
participation of the Company and MSMF will not be on a basis different
from or less advantageous than that of MSC.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Each time the Investment Adviser considers an investment for
MSC, the Investment Committee, for the Company, and the Investment
Adviser, for MSMF, will make an independent determination of the
appropriateness of the investment for the Company and MSMF.
2. (a) If the Investment Committee, for the Company, and the
Investment Adviser, for MSMF, deem that each entity's participation in
the investment is appropriate, then such investment will be made
pursuant to the Relative Allocation Percentages, unless either the
Investment Committee or the Investment Adviser determines that
investment pursuant to the Relative Allocation Percentages is not
appropriate for that investment. The Relative Allocation Percentages
will be determined by both the full Board and the Required Majority in
advance and will be based upon the relative total capital of the
Company and MSMF, on the one hand, and MSC, on the other hand (total
capital being equal to raised equity plus available debt). The Relative
Allocation Percentages will be approved each quarter, or as necessary
or appropriate, between quarters, by both the full Board and the
Required Majority, and may be adjusted, for subsequent transactions, in
their sole discretion for any reason, including, among other things,
changes in the relative aggregate capital of the Company and MSMF vis-
[agrave]-vis the capital of MSC.
(b) If the Investment Committee, for the Company, and the
Investment Adviser, for MSMF, deem that each entity's participation in
the Co-Investment Transaction is appropriate, but that investment
pursuant to the Relative Allocation Percentages is not appropriate,
then the Investment Committee, for the Company, and the Investment
Adviser, for MSMF, will recommend an appropriate level of investment
for each entity. If the aggregate amount recommended by the Investment
Committee, for the Company, and the Investment Adviser, for MSMF, to be
invested in such Co-Investment Transaction, together with the amount
proposed to be invested by MSC in the same transaction, exceeds the
amount of the investment opportunity, the amount proposed to be
invested by each such party will be allocated among them pro rata based
on the ratio of the Company's and MSMF's total assets, on one hand, and
MSC's total assets, on the other hand, to the aggregated total assets
of the three parties, up to the amount proposed to be invested by each.
The Investment Adviser will provide the Required Majority with
information concerning MSC's total assets to assist the Required
Majority with their review of the Company's and MSMF's investments for
compliance with these allocation procedures. After making the
determinations required in this paragraph (b), the Investment Committee
and the Investment Adviser will distribute written information
concerning the Co-Investment Transaction, including the amount proposed
to be invested by MSC, to the Independent Directors for their
consideration. Outside of the Relative Allocation Percentages, the
Company and MSMF will co-invest with MSC only if, prior to the
Company's and MSC's participation in the Co-Investment Transaction, a
Required Majority concludes that:
(i) The terms of the transaction, including the consideration to be
paid, are reasonable and fair and do not involve overreaching of the
Company or its stockholders or MSMF on the part of any person
concerned;
(ii) The transaction is consistent with
(A) The interests of the stockholders of the Company; and
(B) The Company's investment objectives and strategies (as
described in the Company's registration statements on Form N-2 and
other filings made with the Commission by the Company under the
Securities Act of 1933, as amended (``Securities Act''), reports filed
by the Company with the Commission under the Securities Exchange Act of
1934, as amended, and the Company's reports to stockholders);
(iii) The investment by MSC would not disadvantage the Company or
MSMF, and participation by the Company and MSMF is not on a basis
different from or less advantageous than that of MSC; provided, that if
MSC, but not the Company or MSMF, gains the right to nominate a
director for election to a portfolio company's board of directors or
the right to have a board observer or any similar right to participate
in the governance or management of the portfolio company, such event
shall not be interpreted to prohibit the Required Majority from
reaching the conclusions required by this condition (2)(b)(iii), if
(A) The Required Majority shall have the right to ratify the
selection of such director or board observer, if any, and
(B) The Investment Adviser agrees to, and does, provide, periodic
reports to the Company's Board with respect to the actions of such
director or the information received by such board observer or obtained
through the exercise of any similar right to participate in the
governance or management of the portfolio company; and;
(iv) The proposed investment by the Company and MSMF will not
benefit the Investment Adviser or MSC or any affiliated person of
either of them (other than the Company, MSMF, and MSC), except to the
extent permitted under sections 17(e) and 57(k) of the Act.
3. The Company and MSMF have the right to decline to participate in
any Co-Investment Transaction or to invest less than the amount
proposed.
4. Except for follow-on investments made pursuant to condition 7
below, the Company and MSC will not invest in any portfolio company in
which MSC or any affiliated person of MSC is an investor.
5. The Company and MSMF will not participate in any Co-Investment
Transaction unless the terms, conditions, price, class of securities to
be purchased, settlement date, and registration rights will be the same
for the Company and MSMF as for MSC. The grant to MSC, but not the
Company
[[Page 28178]]
or MSMF, of the right to nominate a director for election to a
portfolio company's board of directors, the right to have an observer
on the board of directors or similar rights to participate in the
governance or management of the portfolio company will not be
interpreted so as to violate this condition 5, if conditions
2(c)(iii)(A) and (B) are met.
6. Any sale, exchange, or other disposition by the Company, MSMF,
or MSC of an interest in a security that was acquired in a Co-
Investment Transaction or that is an Existing Co-Investment will be
accomplished pro rata based on the original investment of each
participant unless the Investment Adviser and/or the Investment
Committee formulate a recommendation for participation in a disposition
on a non-pro rata basis and such recommendation is approved by the
Required Majority on the basis that such non-pro rata disposition is in
the best interest of the Company and MSMF. The Company, MSMF, and MSC
will each bear its own expenses in connection with any disposition, and
the terms and conditions of any disposition will apply equally to all
participants.
7. Any ``follow-on investment'' (i.e., an additional investment in
the same entity) by the Company, MSMF, or MSC, or any exercising of
warrants or other rights to purchase securities of the issuer in a
portfolio company whose securities were acquired as an Existing Co-
Investment or in a Co-Investment Transaction will be accomplished pro
rata based on the original investment of each participant unless the
Investment Adviser and/or the Investment Committee formulate a
recommendation for participation in the proposed transaction on a non-
pro rata basis and such recommendation is approved by the Required
Majority on the basis that such non-pro rata participation is in the
best interest of the Company and MSMF. The acquisition of follow-on
investments as permitted by this condition will be subject to the other
conditions set forth in the application.
8. The Independent Directors will be provided quarterly for review
all information concerning (1) all investments made by MSC during the
preceding quarter and (2) Co-Investment Transactions during the
preceding quarter, including investments made by MSC which the Company
and/or MSMF considered but declined to participate in, so that the
Independent Directors may determine whether the conditions of the order
have been met. In addition, the Independent Directors will consider at
least annually the continued appropriateness of the standards
established for co-investments by the Company and MSMF, including
whether the use of the standards continues to be in the best interests
of the Company and its shareholders and does not involve overreaching
on the part of any person concerned.
9. The Company and MSMF will maintain the records required by
section 57(f)(3) of the Act as if each of the investments permitted
under these conditions were approved by the Independent Directors under
section 57(f).
10. No Independent Directors will also be a director, general
partner or principal, or otherwise an ``affiliated person'' (as defined
in the Act) of, MSC.
11. The expenses, if any, associated with acquiring, holding or
disposing of any securities acquired in a Co-Investment Transaction
(including, without limitation, the expenses of the distribution of any
such securities registered for sale under the Securities Act) shall, to
the extent not payable by the Investment Adviser under its investment
advisory agreements with MSMF and MSC, be shared by the Company, MSMF,
and MSC in proportion to the relative amounts of their securities to be
acquired or disposed of, as the case may be.
12. Any transaction fee (including break-up or commitment fees but
excluding broker's fees contemplated by section 17(e)(2) of the Act)
received in connection with a Co-Investment Transaction will be
distributed to the Company, MSMF, and MSC on a pro rata basis based on
the amount they invested or committed, as the case may be, in such Co-
Investment Transaction. MSC or any affiliated person of the Company
will not receive additional compensation or remuneration of any kind
(other than (i) the pro rata transaction fees described above and (ii)
investment advisory fees paid in accordance with investment advisory
agreements with MSMF and MSC) as a result of or in connection with a
Co-Investment Transaction.
For the Commission, by the Division of Investment Management,
under delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8-10802 Filed 5-14-08; 8:45 am]
BILLING CODE 8010-01-P